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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`LG ELECTRONICS INC.,
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`PETITIONER,
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`V.
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`BELL NORTHERN RESEARCH, LLC,
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`PATENT OWNER.
`___________________
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`Case No. IPR2020-00319
`U.S. Patent No. 7,039,435
`___________________
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` JOINT REQUEST TO KEEP SEPARATE PURSUANT TO
`35 U.S.C. § 317 AND 37 C.F.R. § 42.74
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`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioner LG
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`Electronics Inc. (“Petitioner”) and Patent Owner Bell Northern Research, LLC
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`(“Patent Owner”) (collectively, the “Parties”) jointly request that Exhibit 2021, a
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`true copy of the written Settlement and Patent License Agreement (dated July 14,
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`2020) between the Parties referenced in the Joint Motion to Terminate, be treated
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`as business confidential information and be kept separate from the file of the
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`involved patent. The entire settlement documentation is confidential and not
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`publicly available. The present request, which is being filed contemporaneously
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`with the settlement documentation, is timely and in accordance with the foregoing
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`authority.
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`/Timothy W. Riffe/
`Timothy W. Riffe
`Counsel for Petitioner
`Reg. No. 43,881
`FISH & RICHARDSON P.C.
`1000 Maine Ave., S.W.
`Washington, D.C. 20024
`Phone: 202-626-6429
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`/Steven W. Hartsell/
`Steven W. Hartsell
`Counsel for Patent Owner
`Reg. No. 58,788
`SKIERMONT DERBY LLP
`1601 Elm Street, Suite 4400
`Dallas, Texas 75201
`P: 214-978-6600/F: 214-978-6601
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`CERTIFICATE OF SERVICE
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`I certify that I caused to be served on the counsel for Petitioner a true and
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`correct copy of the foregoing Joint Request to Keep Separate Pursuant to 35 U.S.C.
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`§ 317 and 37 C.F.R. § 42.74, by electronic means on July 16, 2020 at the following
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`address of record:
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`Timothy W. Riffe
`riffe@fr.com
`Christopher C. Hoff
`hoff@fr.com
`R. Andrew Schwentker
`schwentker@fr.com
`PTABInbound@fr.com
`IPR18768-0183IP1@fr.com
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`Dated: July 16, 2020
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`Respectfully Submitted,
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`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`Counsel for Patent Owner
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